The Ministry of Finance has released Letter 03-01-18/2676 on February 6, 2013 clarifying the procedure for concluding advance pricing agreements (APAs) for foreign transactions. According to article 105.20 of the Tax Code the Ministry of Finance clarified that a Russian entity that qualifies as large taxpayer can obtain a bilateral or multilateral APA if the foreign transactions involve states with which Russia has concluded tax treaties. Therefore, the taxpayer may file a request to conclude an APA with the Federal Tax Service and with the competent tax authorities of one or more of the states involved.